LivaNova - Ethics and Compliance

To help navigate the complex compliance environment in which we operate, LivaNova has adopted the AdvaMed Code of Ethics on Interactions with Health Care Professionals, the APACmed Code of Ethical Conduct, the Mecomed Code of Ethical Business Practice and the MedTech Europe Code of Ethical Business Practice.

These industry guidelines, along with the LivaNova Corporate Code of Conduct and LivaNova Corporate Compliance Policies, are the foundation of LivaNova's Compliance Program.
 

At LivaNova, we are committed to maintaining an effective and comprehensive compliance program. As a manufacturer of medical devices, LivaNova has designed our Corporate Compliance Program to comply with all applicable U.S. state and federal laws related to the promotion and sales of our products.
 
Our Corporate Compliance Program includes the following:

1. Code of conduct. Our Code of Business Conduct and Ethics is available in multiple languages.
2. Written policies and procedures. Our Corporate Compliance Policies and Procedures are made available to our employees via our Company intranet.
3. Assigned compliance officer. LivaNova has assigned a Compliance Officer who is responsible for implementing our Corporate Compliance Program.
4. Comprehensive training and education. LivaNova is committed to providing our employees with comprehensive compliance training and education on all of our Corporate Compliance policies and procedures.
5. Clear lines of communication for compliance reporting. LivaNova encourages a safe environment for all employees to Speak Up! and raise concerns.
6. Monitoring and auditing. LivaNova actively audits and monitors key processes to ensure compliance with the Company’s compliance policies and procedures.

To our knowledge, LivaNova is, in all material respects, in compliance with the California Health and Safety Code, Sections 119400-119402. Copies of this declaration, as well as additional details regarding our LivaNova Corporate Compliance Program, may be obtained by calling the LivaNova Ethics Line at +1 888-259-8571.
 
Last Updated: September 2018

At LivaNova, we believe it is the responsibility of all stakeholders to ensure we remain reputable leaders in compliance and business ethics. 

We encourage a safe environment for all individuals to speak up and raise any concerns they may have as it relates to the LivaNova Code of Business Conduct and Ethics, a related policy or any integrity issue.

LivaNova does not tolerate any form of retaliation against an individual arising from a good-faith report of a potential violation of our Code of Business Conduct and Ethics, a related policy, any integrity concern or against anyone who participates in an investigation resulting from a report.

You have several options on how to Speak Up:  

Phone

+1 888 259 8571 (Additional local numbers are available here.)
The LivaNova Ethics Line is a toll-free telephone line managed by a third-party provider. If requested and allowable by local law, reporters will be granted full anonymity. The hotline is available globally and in multiple languages. 

Web

http://www.livanova.ethicspoint.com 
The LivaNova Ethics Line can also be reached via web through our third-party managed, confidential and anonymous (if requested and allowable by local law) online reporting tool.

Email

Ethics@LivaNova.com The LivaNova Ethics Inbox is managed by Corporate Compliance and any concerns received will remain confidential.

Contact the LivaNova Compliance Team
 
Nilay Akgerman
Mobile: +44 (0) 777 652 89 05
Compliance Director, International
Office: +44 (0) 7776528905
Email: Nilay.Akgerman@LivaNova.com
 
Germaine Huka
Compliance Manager, Europe
Office: +44 (0)20 3325 0684 / Mobile: +44 (0) 7717 857 401
Email: Germaine.Huka@LivaNova.com 
 
Mark Beyer
Compliance Manager, North America
Office: +1 281 727 2652/ Mobile: +1 823 472 4277
Email: Mark.Beyer@LivaNova.com 
 
Irene Marchi
Global Compliance Program and Data Analytics Manager
Office: +44 (0)20 3325 0683
Email: Irene.Marchi@LivaNova.com     
 
Melanie Cuvillier
Health Care Transparency Specialist
Office: +33 1 85 18 00 52
Email: Melanie.Cuvillier@LivaNova.com
 
Priya Thomas
Health Care Transparency Specialist
Office: +1 281 228 7225
Email: Priya.Thomas@LivaNova.com
 
Lisa Fulcher
Compliance Specialist, North America
Office: +1 281 727 2666
Email: Lisa.Fulcher@LivaNova.com

2017 Modern Slavery and Human Trafficking Statement

LivaNova PLC and its subsidiaries (individually or collectively, “LivaNova”), are committed to the highest ethical standards and compliance with laws and regulations applicable to our business, including laws related to slavery and human trafficking.
 
LivaNova supports the goals of the California Transparency in Supply Chains Act of 2010 and the United Kingdom Modern Slavery Act of 2015 and is committed to eradicating slavery and human trafficking from our supply chains and business activities. We have zero tolerance to slavery and human trafficking. We expect all our suppliers and contractors to adhere to these same fundamental values.
 
As part of our initiative to identify and mitigate risks, LivaNova has taken the following steps and is continuously working to further improve our policies and practices to ensure materials and services provided to LivaNova are procured only from suppliers who share this same level of commitment.
 
This statement sets out our commitment towards these efforts for the fiscal year ending the 31 December 2017.
 
Policies and Internal Accountability
 
LivaNova requires employees, agents, and representatives (together, “Employees”) to comply with our Code of Business Conduct and Ethics., This code mandates compliance with all laws applicable to it or the conduct of its business regardless of location. LivaNova proactively promotes ethical behavior and expects Employees to report violation of laws, rules, regulations, or our Code of Business Conduct and Ethics. LivaNova provides methods for reporting violations or concerns in good-faith, confidentially and anonymously, and fully investigates each report.
 
The Code of Business Conduct and Ethics is available, along with communication channels for reporting violations or concerns in good-faith.
 
Verification
Prior to engaging with a third-party supplier, LivaNova evaluates suppliers through a risk based business review process. Suppliers are expected to comply with applicable laws and regulations, including those related to slavery and human trafficking, as typically specified in our purchase order terms and conditions, contracts, or agreements. 
 
Audit/Due Diligence
LivaNova reserves the right to verify supplier compliance with our defined requirements. We regularly audit suppliers who impact our quality system to confirm services or materials provided conform to defined requirements. Audits are performed by LivaNova or third parties contracted by LivaNova and may include site visits.
 
Certification
LivaNova reserves the right to request immediate corrective action where noncompliance is identified, and has the right to terminate agreements with those suppliers who do not comply with our terms and conditions.
 
While LivaNova requires compliance with all applicable laws in terms and conditions of purchase orders and agreements, we currently do not require our suppliers to certify material and services received comply with the laws specifically related to slavery and human trafficking.
 
Training and Awareness
Training on the Code of Business Conduct and Ethics is provided to LivaNova Employees annually. This training includes ethical decision making, the applicable laws and regulations, and the process for reporting potential compliance concerns. LivaNova’s compliance program also includes written policies and procedures, monitoring and auditing, and the investigation into potential violations with the potential for disciplinary action to be taken when necessary. 
 
Looking Ahead
At LivaNova, our mission is to develop and deliver health innovation that matters. Everything we do is intended to support our mission. We understand and respect the obligation we have to our patients, and their families and caregivers, to operate under the highest standards of business ethics and compliance.
 
LivaNova will continue to work to increase employee awareness, specifically those who are involved with sourcing and buying decisions.  We will continue to work to improve our policies, programs, and procedures for how we identify and mitigate risks in our supply chains to ensure our contractors and third party business partners are upholding the same level of commitment to compliance and business ethics as we do.
 
Damien McDonald
Chief Executive Officer and Director
LivaNova PLC

Archived Statements
2016 Modern Slavery and Human Trafficking Statement Archived 06-08-18

We strive to conduct our activities in a manner that reflects our mission and Code of Business Conduct and Ethics – which includes being a good corporate citizen, dealing fairly in business, behaving ethically, supporting a safe and healthy workplace, doing business in an environmentally responsible manner, and complying with applicable law. We are committed to ensuring that our supply chain reflects our values and beliefs, including adherence to principles of responsible sourcing for materials for our products. As part of our commitment, LivaNova supports the goals and objectives of Section 1502 of the Dodd Frank Act that requires public companies to determine the sourcing of conflict minerals used in their products. We expect our suppliers to support our efforts to comply with the Dodd Frank Act and to proactively identify and work towards eliminating the use of any minerals that fund or benefit armed groups from within our supply chain. In addition, we expect our suppliers to conduct business operations in an ethical manner and to comply with our Code of Conduct and all applicable laws related to environmental responsibility, workplace health and safety, and human resources.
 
View our Conflict Minerals Report.